Detailed Answer

    Section 100A applies where a beneficiary is presently entitled to trust income under a reimbursement agreement entered outside ordinary family or commercial dealing. The result is the trustee being assessed under s 99A at the top marginal rate.

    TR 2022/4 sets out the Commissioner's view, distinguishing 'green zone' (low risk), 'blue zone' (moderate), and 'red zone' (high risk) arrangements. PCG 2022/2 provides the compliance framework.

    The provision has no time limit — the Commissioner can review historical arrangements indefinitely.

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    Key Capabilities

    Primary Sources

    ITAA 1997/1936, GST Act 1999, ATO rulings, Federal Court decisions

    Citation-Aware

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    Professional Review

    Outputs require independent review by an appropriately qualified practitioner

    Why generic AI is risky for 'what is Section 100A'

    • Generic AI tools hallucinate Australian legislative section numbers and ATO ruling identifiers
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    Editorial Standards

    ABN 70 659 258 367
    Australian-registered company
    Publisher
    Cassandra Research — see /about
    Review Required
    An appropriately qualified practitioner must verify the facts, sources and conclusions
    Primary Sources
    ITAA 1997/1936, GST Act 1999, FBTAA, Corporations Act 2001
    Last Updated
    2026-06-01
    Corrections Policy
    See /corrections

    Frequently Asked Questions

    Section 100A is an anti-avoidance provision that targets reimbursement agreements where a trust beneficiary is presently entitled to income but the economic benefit flows to another person, typically to access a lower tax rate.

    Cassandra Research publishes this general overview. This page does not certify individual authorship or a registered practitioner's review; independently check the sources and consult a qualified practitioner before relying on it.

    Check the applicable income year, legislation, ruling status and subsequent decisions directly with the relevant authority. A page date does not establish that the legal position is current. See /corrections to report an issue.

    This page is general information, not personal tax advice. Always confirm with a TPB-registered tax agent or admitted lawyer before relying on it for client work.

    Every primary source referenced — ITAA sections, ATO ruling numbers, and case names — can be verified on the ATO Legal Database, Federal Register of Legislation, or AustLII.

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    Author: Imran Hussain
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